ANNEX 2-7e ANNEX 2-7e PROCEDURAL GUIDELINES FOR SCOPING OF ENVIRONMENTAL RISK ASSESSMENT (ERA) A.

GENERAL GUIDELINES
1. 2. One of the major decision points during the Scoping Process is the determination of the need by the project to undertake an Environmental Risk Assessment (ERA) or not. As defined by DAO 2003-30, ERA is the use of universally accepted and scientific methods to assess the risks associated with a project. It focuses on determining the probability of occurrence of accidents and their magnitude (e.g., failure of containment or exposure to hazardous materials or situations.) An ERA is not an entirely separate assessment but deals with the further analysis of hazards identified in the EIA. It builds upon the EIA such that risks are impacts where the likelihood of occurrence and magnitude of consequences are uncertain.

3.

The decision of whether to include an ERA in the EIS should be discussed and agreed upon during the scoping activity (i.e., technical scoping). A sound basis for arriving at a resolution would be to refer to experiences elsewhere that have similar materials, processes and conditions. 4. It should be noted that the ERA, within the context of Philippine EIS System, is concerned primarily with safety risks (characterized by low probability, high consequence, accidental nature and acute effects [human safety focus]). In contrast, geological risks are covered by the EGGAR requirement under the MGB while health risks (characterized by high probability, low consequence, ongoing or continuing exposure and chronic human health effects) are assessed in the environmental health impact assessment under the DOH mandate. This section deals only with system procedures of the ERA requirements. Technical guidelines and other reference materials on ERA may be found in the following materials: Guidance on the Control of Major Accident Hazards Regulations 1999 . Health and Safety Executives, UK Guidelines for Chemical Process Quantitative Risk Analysis . Center for Chemical Process Safety, American Institute of Chemical Engineers Loss Prevention in the Process Industry. Frank P. Lees PLEASE REFER BELOW TO SECTION II on the Technical Guidelines for the Conduct of ERA for the technical definitions and required format and content of the ERA. B. LEVELS OF COVERAGE AND SCOPING REQUIREMENTS 6. The requirement for the conduct of ERA shall be defined at three (3) levels: a) Level 2 for facilities that will use, manufacture, process or store hazardous materials in excess of Level 2 threshold inventory shall be required to conduct a Quantitative Risk Assessment (QRA) and prepare an Emergency/Contingency Plan based on the results of the QRA. b) Level 1 for facilities that will use, manufacture, process or store hazardous materials in excess of Level 1 threshold inventory shall be required to prepare an Emergency/Contingency Plan based on the worst case scenario. The Plan shall be based on a Hazard Analysis study. c) Risk screening level specific facilities or the use of certain processes shall require the conduct of a risk screening study even if the projected or estimated inventory does not reach the threshold levels. 7. As stated, projects or undertakings categorized as Level 2 shall be required to conduct a Quantitative Risk Assessment (QRA) and prepare an Emergency/Contingency Plan based on the results of the QRA. While projects or undertakings categorized as Level 1 shall be required to prepare an Emergency/Contingency Plan based on the worst case scenario (as a result of a Hazard Analysis study.)

5.

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Scoping

Material inventory exceeds LEVEL 2 threshold?

no

yes

Prepare Quantitative Risk Assessment

Material inventory exceeds LEVEL 1 threshold?

no

yes

Prepare Emergency Plan based on Hazard Analysis

Is activity listed in covered project for risk screening?

no

yes

Prepare Risk Sreening

Project not covered by ERA

no

Does risk screening warrant preparation of emergency plan?

yes

8.

Projects or undertakings that are not categorized as Level 1 or Level 2, but is contained in the list for risk screening, shall be require to conduct a risk screening study even if the projected or estimated inventory does not reach the threshold levels. The submission of a risk screening study does not preclude DENR-EMB from further requiring the proponent to submit a hazard analysis or QRA if necessary. DENR-EMB may order the proponent to submit a hazard analysis or QRA if the proposed project has high potential to cause significant public (safety) risks Furthermore, it should be noted that the ERA coverage levels is independent (i.e., not linked) to the EIS documentary requirements. It is possible that a project or undertaking submitting an IEE Report will be required to submit a QRA. In the same analogy, a project or undertaking required to submit a full EIS may only be required to submit a risk screening study. II. TECHNICAL GUIDELINES FOR THE CONDUCT OF ENVIRONMENTAL RISK ASSESSMENT

9.

A. Determination of Risk Levels 1. Levels of Coverage and Requirements a. Risk Screening Level. The following activities are required to undertake a risk screening exercise: 1) Facilities for the production or processing of organic or inorganic chemicals using: a) alkylation b) amination by ammonolysis c) carbonylation d) condensation e) dehydrogenation f) esterification

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g) h) i) j) k) l) m) n) o) p) q) r) s) 2) 3) 4) 5) 6) 7) halogenation and manufacture of halogens hydrogenation hydrolysis oxidation polymerization sulphonation desulphurization, manufacture and transformation of sulphur-containing compounds nitration and manufacture of nitrogen-containing compounds manufacture of phosphorus-containing compounds formulation of pesticides and of pharmaceutical products. distillation extraction solvation

Installations for distillation, refining or other processing of petroleum products. Installations for the total or partial disposal of solid or liquid substances by incineration or chemical decomposition. Installations for the production or processing of energy gases, for example, LPG, LNG, SNG. Installations for the dry distillation of coal or lignite. Installations for the production of metals or non-metals by a wet process or by means of electrical energy. Installations for the loading/unloading of hazardous materials as defined by RA 6969 (or DAO 29)

2. Levels 1 and Level 2 Threshold Inventory. The following threshold levels shall be used to determine whether a proposed project or undertaking shall be required to prepare a QRA and/or an emergency/contingency plan: CATEGORY Explosives Flammable substances Highly flammable substances Extremely flammable substances Oxidizing substances Toxic substances (low) Toxic substances (medium) Toxic substances (high) Toxic substances (very high) Toxic substances (extreme) Unclassified (Type A) Unclassified (Type B) LEVEL 1 (tons) 10 5,000 50 10 50 50 10 5 0.2 0.001 100 50 LEVEL 2 (tons) 50 50,000 200 50 200 200 50 20 1 0.1 500 200

Definition of different categories of hazardous materials: Category Definition A. Explosives (Reactivity) 1. A substance or preparation which creates the risk of an explosion by shock, friction, fire, or other sources of ignition. 2. A pyrotechnic substance (or mixture of substances) designed to produce heat, light, sound, gas, or smoke or a combination of such effects through non-detonating self-sustained exothermic chemical reactions. B. Flammable 1. Flammable substances are substances and preparations having a flash Substances point equal to or greater than 21*C and less than or equal to 55*C, capable of supporting combustion. (Highly flammable and extremely flammable 2. Highly flammable substances are substances and preparations which may become hot and finally catch fire in contact with air at ambient

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substances)

3.

C. Oxidizing substances D. Toxic Substances 1. 2. 3. E. Unclassified Substances

temperature without any input of energy, or substances which have a flash point lower than 55*C and which remain liquid under pressure, where particular processing conditions, such as high pressure or high temperature, may create major-accident hazards. Extremely flammable substances are liquid substances and preparations which have a flash point lower than 0*C and the boiling point (or, in the case of a boiling range, the initial boiling point) of which at normal pressure is less than or equal to 35*C; gaseous substances and preparations which are flammable when in contact with air at ambient temperature and pressure, whether or not kept in the gaseous or liquid state under pressure; or, liquid substances or preparations maintained at a temperature above their boiling point. Substances which give rise to highly exothermic reaction when in contact with other substances, particularly flammable substances. Low, medium, high, very high and extreme toxicity of substances or preparation are classified as follows: A substance shall be considered as a liquid if vapor pressure is less than 1 bar at 20*C. A substance shall be considered as a gas if vapor pressure is greater than 1 bar at 20*C. The sum of (a) and (b) as provided in Tables 2 and 3 shall determine the toxicity class as contained in Table 1. Substances or preparations that react violently with water (Type A), and substances or preparations which release or liberate toxic gas in contact with water (Type B).

Mixtures and preparations shall be treated in the same way as pure substances provided they remain within the level set according to their properties or their latest adaptation to technical progress unless a percentage composition to other description is specifically provided for. The bases for determination of the level are the maximum quantities which are present or likely to be present at any one time. The rule for the presence of several hazardous or dangerous substances in an establishment shall be as follows: Total indicative sum = q1/Q1 + q2/Q2 + q3/Q3 + * * * + qn/Qn Where: q = the quantity of dangerous substance Qx = the indicative threshold level of dangerous substance x If the computed Total Indicative Sum is greater than 1.0, then the project or undertaking is covered and shall be required to prepare an ERA. a+b 6 7 8 9 10 Table 1. Table for values to determine Toxicity Class Toxicity Class Low Medium High very high extreme

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Table 2. Table for values of a based on LC50 LC50 rate 4 hour in ppm Calculation number (a) 0.01 0.1 8 0.1 1 7 1 10 6 10 100 5 100 1,000 4 1,000 10,000 3 10,000 100,000 2 Table 3. Table for values of b based on physical properties Physical Properties Calculation number (b) Liquids < 0.05 bar 1 (vapor pressure) 0.05-0.3 bar 2 at 20C) 0.3-1 bar > 265K < 265K > 245K < 245K 3 3 4 3 4 Liquefied gas, compressed (BP) Liquefied gas, cooled (BP) BP: Boiling Point B. Report Formats and Other Requirements 1. An Environmental Risk Assessment (ERA) Report, which forms part of the EIS as a separate chapter, is prepared to demonstrate the following: a) that a major accident prevention policy and a safety management system for implementing it have been put into effect by the proponent; b) that major accident hazards have been identified and that the necessary measures have been taken to prevent such accidents and to limit their consequences for man and the environment; c) that adequate safety measures and reliability have been incorporated into the design, construction, operation and maintenance of any installation, storage facility, equipment and infrastructure connected with its operation which are linked to major accident hazards inside the establishment; d) that an on-site emergency plan has been drawn up to implement the necessary measures in the event of a major accident; e) that in case of major accident, decontamination, remediation and/or rehabilitation measures will be undertaken; and f) that sufficient information is provided to enable decisions to be made in terms of the siting of new activities or developments around existing establishments. 2. The ERA Report (e.g., risk screening, hazard analysis, QRA) shall be prepared as a separate chapter of the EIS. It shall contain at least the following data and information: a) Information relating to the operator and the establishment the proponents major accident prevention policy including the overall aims and principles of action with respect to the control of major accident hazards; and the proponents conceptual framework for the safety management system, including (if available), the criteria to evaluate or determine such identified indicators. Information relating to the scope of analysis employed/used in the report coverage of the report, the methodology used in each of the stages of analysis and assumptions made (if there are any) in coming up with the results of analysis; and

b)

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references shall likewise be acknowledged in the report, whether these are historical data or generic information that aided the analysis attain more reliable results. Information relating to every hazardous substance or situation present in the establishment, in particular: the identification of the hazardous substance: chemical name, CAS number, name according to International Units of Pure and Applied Chemistry (IUPAC) nomenclature; the physical and chemical properties of the toxic/hazardous substance present in the establishment (under normal conditions of use or under foreseeable accidental conditions) and the maximum amount that could possibly be present at any one time; the degree of purity of the substance, and the identification of the main impurities and their percentages, if available; a description of the hazards, both immediate (acute effects) and delayed (chronic effects) for man and the environment, which may be posed by the substance or situation; and a description of the potential sources of a major accident and the conditions or events, which could be significant in bringing one about. Information relating to the consequences of major accidents, the probability of its occurrence, and an estimation of the risk, namely detailed description of the possible major accident scenarios including a summary of events which may play a role in triggering each of these scenarios, the causes being internal or external to the establishment or installation; a description of the methodology adopted, data used and results of analysis in estimating the probable consequence(s) of the predicted major accident that may result within the establishment with an estimate of the number of people in the possible affected area who may be particularly exposed to the hazards considered in the report as well as the major ecosystem that will be affected; whenever possible, a discussion on the probability of occurrence of the potential accident scenario(s) identified in the report; and an assessment of risk(s) associated with the activity inside the establishment.

c)

d)

3. For QRA, the Report shall also contain: a) a map, preferably topographic or population map, on a scale of 1:10,000 or larger, which would show (whenever possible) significant locations including risk contour lines identifying those positions outside the industrial site wherein the probability of persons located there would die as a result of an unusual occurrence in the industrial site equals 10-4, 10-5, 10-6, 10-7 and 10-8, respectively; and b) a map, preferably topographic or population map, on a scale of 1:10,000 or larger, which would show (whenever possible) other source/s or establishments of significant risk within 10 km, including risk contour lines identifying these sources and the computed total risk with the addition of the establishment covered in the Safety Report. 4. For Level 1 and Level 2 coverage, information relating to the safety management system for the establishment, namely: a) a description of the measures taken to prevent, control, or minimize the consequences and probability of any major accident; b) information about the emergency procedures laid down in dealing with a major accident occurring at the site (a copy of the On-Site Emergency Plan shall be attached); c) the monitoring scheme for the continuing assessment of compliance with the objectives of the major accident prevention policy and safety management system, and the mechanisms for investigation and taking corrective action in case of non-compliance. The procedures shall cover the operators system for reporting major accidents or near misses, particularly those involving failure of protective measures, and their investigation and follow-up on the basis of lessons learned. d) the staffing arrangements for controlling the industrial activity with the name of the person responsible for safety on the site and the names of those who are authorized to set emergency procedures in motion and to inform outside authorities;

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e) f) the arrangements made to ensure that the means provided for the safe operation of the industrial activity are properly designed, constructed, tested, operated, inspected and maintained, and the arrangements for training of persons working on the site; and the audit and review scheme for periodic and systematic assessment of the major accident prevention policy and the effectiveness and suitability of the safety management system, including the documentation of review of performance of the policy and the system and its updating by senior/top management. An Emergency Plan is prepared with the following objectives: to contain or control incidents so as to minimize the effects, and limit damage to man, the environment and property taking into consideration the worst-case scenario; to implement the measures necessary to protect man and environment from the effects of major accidents; to communicate the necessary information to the public and to the emergency service provider (such as fire protection, civil defense. disaster coordination and other appropriate local government unit or agency) in the area; and to provide for the restoration and clean up of the environment following a major accident.

5. a) b) c) d) 6.

The Emergency Plan shall be prepared as a separate chapter of the EIS for Level 1 Coverage (together with the Hazard Analysis study), or as an annex (of the QRA) for Level 2 Coverage. It shall contain at least the following data and information: a) On-site Emergency Plan Names or positions of persons authorized to set emergency procedures in motion and the person in charge of coordinating the on-site mitigatory action. Name or position of the person with responsibility for liaising with the authority responsible for the off-site emergency plan. For foreseeable conditions or events which could be significant in bringing about a major accident, a description of the action which should be taken to control the conditions or events and to limit their consequences, including a description of the safety equipment and the resources available. Arrangements for limiting the risks to persons on site including how warnings are to be given and the actions persons are expected to take upon receipt of a warning. Arrangements for providing early warning of the incident to the authority responsible for setting the off-site emergency plan in motion, the type of information, which should be contained in an initial warning and the arrangements for the provision of more detailed information as it becomes available. Arrangements for training the staff in the duties they are expected to perform, and where necessary, coordinating this with off-site emergency services. Arrangements for providing assistance with off-site mitigatory action. Linkage with Off-Site Emergency Plan Names or positions of persons authorized to set emergency procedures in motion and of persons authorized to take charge of and coordinate with off-site emergency services. Arrangements for sending early warning of incidents, alert, and call-out procedures. Arrangements for coordinating resources necessary to implement the off-site emergency plan. Arrangements for assistance to provide the public with specific information relating to the accident and the behavior which the public should adopt. Arrangements for the provision of information to the appropriate emergency services of surrounding areas in the event of a major accident with possible trans-boundary consequences.

b)

7.

The findings, recommendations and conclusions of the ERA must be integrated in the Environmental Management Plan (EMP) as a safety management plan. Details of the safety

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management system including proposed monitoring or auditing protocols must be incorporated in the EMP. 8. Together with the EMP, a corresponding Safety Monitoring Plan should be prepared. The plan should include the following information per project activity for each project phase: a) b) c) d) e) 9. parameters or criteria to be monitored; location of monitoring activity; frequency of monitoring activity; cost of monitoring activity; and implementing or responsible group

The proponent is also strongly urged to maintain comprehensive records of safety information (e.g., incidents, near-incidents, injuries, training, failure of equipment/fixtures, etc.). The information will not only be helpful for regulatory purposes, but also for corporate management weak areas in terms of safety management can be identified before grave incidents may occur

C.

Risk Criteria for EIA Review 1. a) b) c) Individual Risk Criteria Individual risk criteria have been developed based on the principle that involuntary risks due to industrial developments should not significantly increase the level of risk to individuals living or working near such industry. Location Specific Individual Fatality Risk (LSIFR) is the risk of death to an individual person, if present 24 hours per day (in the open) at a particular location for a whole year. It takes no account of the number of people affected by an event. LSIR is normally represented in the form of risk contours. This is achieved by plotting and connecting all points (locations) of similar individual risk, thus forming risk contours (not dissimilar to isobars on a weather map). These contours can then be overlaid onto a land-use map to show the level of individual risk in the various land-use planning areas. Individual risk criteria may be applied and measures taken to ensure that no single individual living near to a hazardous activity bears an undue level of risk. Without prejudice to the supplemental guidelines that may be issued by the DENR Secretary, the acceptable individual risk criterion is set at 10-6 fatalities per year. Safety and/or mitigation measures should be incorporated such that hazard zones and the 10 -6 individual risk per year contour DO NOT encroach into residential (I.e., non-industrial/non-commercial) areas. Societal Risk Criteria a) The greater public concern for events causing a large number of deaths is best reflected in terms of the societal risk criteria. The establishment of societal risk criteria is recognition that multiple fatality events should be regarded as more serious than events capable of causing only a few fatalities. Another point to be considered is the level of benefit society may derive from an existing or proposed development. Care must be taken to ensure that the local population does not suffer an unfair burden of risk in respect to the benefits of the population at large. Societal risk is another suitable basis for review of hazardous facilities. This has a different emphasis from individual risk. Societal risk measures the number of fatalities caused by a full range of more or less frequent incidents. These are normally presented on a log-log plot of the cumulative frequency of incidents causing N or more fatalities versus the number of fatalities, N. Societal risk criteria specify levels of societal (group) risk, which must not be exceeded by a particular activity. These should ensure that a hazardous activity does not impose a risk on society that is out of proportion to other types of hazards and with the benefits the activity brings, which individual risk does not address.

d) e)

2.

b) c)

d)

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e) Without prejudice to the supplemental guidelines that may be issued by the DENR Secretary, the acceptable societal risk criterion is an FN curve with slope = 1 and with intercept at N = 1 of 10 3. In cases of co-located projects, the criterion may be adjusted by DENR-EMB by one order of magnitude higher.

Figure 1. Societal Risk Criteria

3

10

Intolerable
10
4

Frequency of N or more Fatalities per year (F)

10

ALARP
106

10

108 1

Acceptable
10 100 1,000 10,000

Number of Fatalities (N)

139